Client virtual assets (including where the firm controls keys or seed phrases) are not the firm's assets or liabilities and fall outside its estate; hold them in wallets separate from the firm's own, labelled Client VA Wallet in the records, one-to-one without rehypothecation unless the client gives explicit prior discretionary consent and the firm is licensed for the activity; pass airdrops, staking gains and similar proceeds to clients unless agreed otherwise (with disclosed de minimis thresholds); take no ownership except into a trust for clients within one day; meet VARA's proof of reserves requirements; reconcile each client's holdings daily and notify VARA of unresolved material discrepancies.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.